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Rev. Proc. 2026-17: Withdrawal of Sec. 163(j)(7) elections
Businesses should review interest limitation elections filed with 2022–2024 returns. Under the revenue procedure, certain taxpayers can withdraw past elections, potentially changing interest and depreciation treatment.
Tax Court addresses disallowance of DRD and FTC
Tax Court disallows part of a taxpayer’s Sec. 245A dividends-received deduction and holds post–Sec. 965(c) amount must be included in formula to determine Sec. 245A(d)(1) foreign tax credit disallowance.
Transfer pricing treatment of acquired intangibles
After a cross-border merger or acquisition, related affiliates often integrate and use the acquired intangibles, such as new products or innovative features. To help executives manage the resulting transfer pricing risk, this article examines the treatment of acquired intangibles in post-acquisition related-party transactions.
Effect of the new pro rata share rules
Even though recent changes substantially reduced abuse concerns, U.S. corporate shareholders must still comply with the extraordinary reduction rules when deducting certain foreign dividends.
The new CFC tax landscape after OBBBA
H.R. 1, P.L. 119-21, known as the One Big Beautiful Bill Act, introduced significant changes to the controlled foreign corporation rules that affect U.S. taxpayers with foreign corporate interests. Two key amendments introduced under Section 70353 of the OBBBA are particularly noteworthy.
‘Stacking’ charitable contributions up to the 60% limit
The OBBBA sought to clarify AGI‑based charitable contribution deduction limits but instead added uncertainty over how those limits apply.
Sec. 163(j) after OBBBA: Leveraging cost-recovery accounting methods
A variety of capitalization strategies can increase deductible interest expense now that depreciation, amortization, and depletion are again added back to adjusted taxable income in calculating the Sec. 163(j) interest limitation.
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including
court cases, rulings, and guidance issued during the six months ending October 2025.
Current developments in taxation of individuals: Part 1
This update surveys recent federal tax developments involving individuals, including
court cases, rulings, and guidance issued during the six months ending October 2025.
Estate planning in a post-OBBBA world
Strategies for optimal intergenerational wealth transfer may require reconsideration, given the continuation of a higher basic exclusion amount by the law known as the One Big Beautiful Bill Act.
Application of grandfathering rules under Sec. 162(m) to severance plan payments
The rules hinge on whether a corporation remains obligated since Nov. 2, 2017, to pay an amount under a written binding contract that has not been materially modified after that date.
A lower substantial-improvement threshold for rural opportunity zones
In the new zones, business property can become qualified if improvements increase its basis by 50%, rather than the otherwise applicable 100%.
Sec. 174: The OBBBA and growing state tax disconformity
State conformity or decoupling from Sec. 174 and new Sec. 174A, enacted by the law known as the One Big Beautiful Bill Act, complicates the treatment of research and experimental expenditures.
Cap raised, strings attached: The 2025 SALT shake-up
Advisers can help clients take advantage of the higher deduction limit for state and local taxes while managing its income phaseout and scheduled sunset.
AICPA seeks guidance on Sec. 174A(c) capitalization and amortization of R&E
Requested guidance can be provided through modifications to Rev. Proc. 2025-28 and/or other published guidance.
AICPA tax policy and advocacy successes: 2025 highlights
The AICPA’s Tax Division volunteer committees and technical resource panels can point to many positive results last year from its advocacy to Treasury, the IRS, and Congress for law changes and administrative guidance.
Practical tax advice for businesses as a result of the OBBBA
H.R. 1, P.L. 119-21, the law commonly known as the One Big Beautiful Bill Act (OBBBA), contains provisions of special interest to business taxpayers. This article summarizes some of them and offers tax planning tips.
Comparing and contrasting business tax strategies
Using the correct expensing strategy for items of real and personal property enables taxpayers to obtain the maximum tax benefits.
Income tax purchase accounting considerations for a stock acquisition
Business advisers can help guide clients through the tax and accounting considerations of a corporate sale or purchase.
Recent developments in estate planning
This annual update on trust, estate, and gift taxation covers recent IRS guidance and administrative issuances, relevant legislative proposals, and selected court decisions for the period ending June 2025.
